Phoenix Area Ozone Actions · percent plan for the Phoenix area which is contained in the MAG 1993 Ozone Plan for the Maricopa County Area (November 1993) (MAG 1993 Plan) and its

FINAL

Technical Support Document

for

the Notice of Final Rulemaking

on

the Clean Air Act Section 182(b)(1)

15 Percent Rate of Progress Requirement

for

the Phoenix Metropolitan Ozone Nonattainment Area

May 18, 1998

Air Division U.S. Environmental Protection Agency - Region 9

Final TSD for the Phoenix Metro 15 Percent Plan

Table of Contents

I. Introduction and Background

A. Introduction

B. Background 1. Arizona’s 15 Percent Plan for the Phoenix Area 2. EPA’s 15 Percent ROP Plan Obligation

II. Clean Air Act and EPA Policy Requirements for 15 Percent Plans

A. Fifteen Percent VOC Rate of Progress Requirement

B. Determining the Fifteen Percent Rate of Progress Target

C. Post-1996 Emission Reductions Creditable to the 15 Percent Rate of Progress Demonstration

III. 15 Percent Rate of Progress Demonstration

A. 1990 Base Year Inventory 1. State Inventory 2. Adjustments to the Base Year Inventory

B. 15 Percent Rate of Progress Target Calculation

C. Control Measure Evaluation 1. Stationary Point and Area Source Controls 2. Non-road Mobile Source Controls a. Emission Reductions from RVP Limits b. Emission Reductions from Federal Phase I RFG c. Emission Reductions from the Federal Non-Road

Engine Standards d. Summary of Non-Road Emission Inventory

i

Final TSD for the Maricopa County 15 Percent Plan

Table of Contents - Continued

3. On-Road Mobile Source Controls a. 1996 Baseline Inventory b. On-Road Motor Vehicle Controls

i. State RVP Limit ii. Enhanced I/M Program iii. Federal Phase I RFG Program

c. Calculation of On-Road Emission Inventory d. Summary of On-road Emission Inventory

D. 15 Percent Determination

IV. “As Soon As Practicable” Demonstration

V. Responses to Public Comments Received on the Proposed Action

Appendices

Appendix 1 - Review of the 1990 Base Year Emissions Inventory for the Maricopa County Ozone Nonattainment Area

Appendix 2 - MOBILE5a (3/29/97) Input and Output Files and Composite Emission Factor Table for Adjustments to the Base Year Inventory

Appendix 3 - MOBILE5a (3/29/97) Sample Input Files, Composite Emission Factor Tables, and Total On-Road Inventory Tables for FMVCP and RVP Impacts

Appendix 4 - Point and Area Stationary Source Projected Emission Inventory Tables

Appendix 5 - Non-Road Engine Emission Inventory Tables

Appendix 6 - MOBILE5a (3/29/97) Sample Input and Output Files, Composite Emission Factor Tables, and Total On-Road Inventory Tables for Control Measure Evaluation

ii

Final TSD for the Maricopa County 15 Percent Plan May 18, 1998

Final Technical Support Document for

the Notice of Final Rulemaking

on the 15 Percent Rate of Progress Requirements in the Phoenix Metropolitan Ozone Nonattainment Area

I. Introduction and Background

A. Introduction

This technical support document (TSD) supports EPA's final determination under Clean Air Act (CAA) section 110(c) that the Phoenix, Arizona moderate ozone nonattainment area has in place sufficient control measures to meet the 15 percent rate of progress (ROP) requirement in Clean Air Act section 182(b)(2). This finding is based in part on EPA’s analysis of Arizona’s 15 percent plan for the Phoenix area which is contained in the MAG 1993 Ozone Plan for the Maricopa County Area (November 1993) (MAG 1993 Plan) and its Addendum (March 1994) and Modeling Attainment Demonstration (October 1994) and in part on EPA's analysis of additional federal measures that affect emissions in the Phoenix area.1 EPA proposed this determination on January 26, 1998 (63 FR 3687).

This TSD also supports EPA's final approval under CAA sections 110(k) and 182(a)(1) of the 1990 base year emission inventory for the Phoenix ozone nonattainment area. This inventory was submitted by the State on April 1, 1993.

The Phoenix metropolitan area was originally classified as a moderate ozone nonattainment area on November 6, 1991. EPA has recently found that the Phoenix area failed to attain the 1-hour ozone NAAQS by the statutory deadline for moderate areas of November 15, 1996. As a result of this finding the area has been reclassified to serious. See 62 FR 60001 (November 6, 1997). However, this reclassification does not affect the requirement for a 1990 base year inventory or a 15 percent ROP demonstration.

This TSD is divided into three parts. The first part provides statutory and EPA requirements for 15 percent ROP plans. The second part provides EPA’s evaluation of the area’s compliance with 15 percent ROP requirement. The final part provides EPA's detailed responses to the comments received on the proposed action.

1These documents were submitted by the Arizona Department of Environmental Quality (ADEQ) on November 15, 1993; April 8, 1994; and November 14, 1994, respectively. The State also submitted Revisions to the Modeling Attainment Demonstration, March 1995 on March 31, 1995, which dealt solely with the attainment demonstration and did not affect the 15 percent plan. The State submitted additional ozone controls in the Voluntary Early Ozone Plan for the Metropolitan Phoenix Area (VEOP) on April 21, 1997. The VEOP did not include any revisions to the 15 percent ROP demonstration in the MAG 1993 Plan.

U.S. EPA Region 9 Page 1


B. Background

1. Arizona’s 15 Percent Plan for the Phoenix Area

On April 13, 1994, EPA found the 15 percent ROP demonstration contained in the November 15, 1993 submittal of the MAG 1993 Plan incomplete under Clean Air Act (CAA or Act) section 110(k)(6)(1)(B) because it failed to include, in fully adopted and enforceable form, all of the measures relied upon in the 15 percent demonstration. This incompleteness finding started the 18-month sanction “clock” in CAA section 179 and the two-year clock under section 110(c) for EPA to promulgate a federal implementation plan (FIP) covering the 15 percent ROP requirement. Subsequently Arizona supplemented the original submittal with the Addendum and Modeling Attainment Demonstration, both of which updated the 15 percent ROP demonstration. Based on these supplemental submittals, EPA found the 15 percent ROP and the attainment demonstrations complete on May 12, 1995, turning off the sanctions clock.2 Under section 110(c), however, the FIP clock continues until EPA approves the 15 percent plan.

The 15 percent ROP demonstration in the MAG 1993 Plan relied primarily on improvements to the State’s vehicle emissions inspection and maintenance program (I/M), a summertime gasoline volatility (RVP) limitation of 7.00 pounds per square inch (psi), numerous stationary and area source control measures, and a number of transportation control measures. Since 1995, EPA has acted to approve many of the control measures contained in the 1993 MAG Plan and VEOP but has not acted on the overall 15 percent ROP demonstration.

Improvements to the State’s I/M program (known as the Vehicle Emissions Inspection Program (VEIP)) included biennial IM240 transient testing for model year 1981 and newer vehicles, more stringent testing cut points (the tailpipe emissions levels at which cars are failed), pressure and purge testing, increased waiver limits, improvements to the anti-tampering program, and a remote sensing program. These I/M improvements accounted for 50 percent of the emission reductions necessary to show the required ROP. See Addendum, page 3-6. In designing its enhanced VEIP, Arizona relied in good faith on the technical specifications and associated emission reductions in EPA’s enhanced I/M regulations, 40 CFR part 51, subpart S as promulgated on November 5, 1992 (57 FR 52950).

Arizona began to implement the improvements to its I/M program in early 1995 and quickly determined that EPA's pressure and purge test could not be implemented in practice in I/M testing lanes, and consequently suspended the tests. The State subsequently redesigned the pressure test and began implementing it in 1996. No effective purge test, however, is currently available. EPA continues to work to develop such a test and Arizona remains committed to implementing a test when it becomes available.

2The VEOP became complete by operation of law under CAA section 110(k)(1)(B) on October 18, 1997.



Early testing of the final cut points assumed in the State's 15 percent plan also indicated that they would not work in practice because of unacceptably high false failure rates (i.e., failing cars that should have passed) of up to 50 percent. Arizona is currently working to develop alternatives to the final cut points and intends to begin implementing those alternatives as early as 1999.

The purge test and the final cut points accounted for roughly 60 percent of the total emission reductions expected from the VEIP and 30 percent of the emission reductions necessary to show 15 percent ROP. In part to replace these lost emission reductions and in part to ensure continued progress toward attainment of the ozone standard in the Phoenix area, the State opted into EPA’s federal reformulated gasoline program in 1997 (60 FR 30260 (June 3, 1997)) and has recently adopted its own, more stringent Cleaner Burning Gasoline (CBG) program as a replacement for the federal RFG program. EPA approved the State's CBG program on February 10, 1998. 63 FR 6653.

2. EPA's 15 Percent ROP Plan Obligation

In August 1996, EPA was sued by the American Lung Association of Arizona, American Lung Association of Arizona (ALAA) Inc., et al v. Browner, No. CIV 96-1856 PHX ROS (D.Ariz.). This case sought to enforce EPA’s obligation under CAA section 110(c) to promulgate a federal plan for the 15 percent ROP requirement. On July 8, 1997 a consent decree was filed with the U.S. District Court for the District of Arizona establishing a schedule of January 20, 1998 for proposing and May 18, 1998 for promulgating a 15 percent ROP plan. Under the consent decree, EPA’s obligation to promulgate a plan is relieved to the extent that it has approved State measures.

The State’s 15 percent plan as revised and submitted in 1993 through 1995 does not reflect the changes to the control strategy necessitated by the problems with enhanced I/M and the implementation of the federal RFG program. In addition, EPA guidance requires a recalculation of the 15 percent target emission level if post-1996 emissions reductions (such as those from the RFG program) are to be credited to the 15 percent plan. As a result, EPA has not received a complete state submittal containing a revised 15 percent ROP demonstration that it could act on without additional analysis, public hearing and adoption by the State. Consequently EPA is complying with ALAA consent decree today by promulgating, pursuant to its CAA section 110(c) FIP authority, a federal 15 percent ROP plan for the Phoenix area. EPA's analysis upon which this FIP is passed is provided in this TSD.

II. Clean Air Act and EPA Policy Requirements for 15 Percent Plans

A. Fifteen Percent VOC Rate of Progress Requirement

CAA section 182(b)(1) requires each ozone nonattainment area classified as moderate or above to develop plans to reduce volatile organic compounds (VOC) emissions in the area by 1996 by 15 percent from 1990 baseline levels. This requirement is referred to as the 15 percent rate of progress or 15 percent ROP requirement.



CAA section 182(b)(1)(A)(i) states that

By no later than [November 15, 1993], the State shall submit a revision to the applicable implementation plan to provide for volatile organic compound emission reductions, [by November 15, 1996], of a least 15 percent from baseline emissions, accounting for any growth in emissions after 1990.

Baseline emissions are defined in CAA section 182(b)(1)(B) as

...the total amount of actual VOC or [nitrogen oxides] emissions from all anthropogenic sources in the area during the calendar year [of 1990], excluding emissions that would be eliminated under the regulations described in clauses (i) [Federal Motor Vehicle Control Program] and (ii) [gasoline volatility rules] of subparagraph (D).

EPA has interpreted the baseline emission inventory to be a typical ozone season weekday inventory for all anthropogenic sources in the nonattainment area. This guidance stems from the fact that the ozone NAAQS is an hourly standard that is generally violated during ozone season (generally summer) weekdays when conditions are conducive to ozone formation. General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 (“General Preamble”), April 16, 1992, 57 FR 13498 at 13507.

The Act sets limitations on the creditability of certain control measures in ROP demonstrations. Emission reductions from the following programs cannot be used to demonstrate the 15 percent ROP:

C Federal Motor Vehicle Control Program (FMVCP) as promulgated prior to January 1, 1990. Section 182(b)(1)(D)(i).

C Gasoline volatility (Reid vapor pressure (RVP)) regulations promulgated prior to November 15, 1990 or required to be promulgated under section 211(h). Section 182(b)(1)(D)(ii)

C Corrections to reasonably available control technology (RACT) rules required by section 182(a)(2)(A). Section 182(b)(1)(D)(iii).

C Corrections to inspection and maintenance programs (I/M) required under section 182(a)(2)(B). Section 182(b)(1)(D)(iii)

All other measures are creditable provided they are 1) measures in the State Implementation Plan (SIP), 2) promulgated by EPA, or 3) included in a title V operating permit. See CAA section 182(b)(1)(C). All creditable emission reductions must be real, permanent, and enforceable and not double-counted (i.e., reductions cannot be used for offsets and to meet the 15 percent ROP requirement). General Preamble at 13509. Emission reductions must come from



sources in the baseline inventory. Emission reductions from sources outside the nonattainment area are not creditable. General Preamble at 13509.

B. Determining the 15 Percent Rate of Progress Target

To demonstrate that the 15 percent ROP requirement has been met in an area, the 1996 projected emission levels in that area must be at or below the 15 percent ROP target level. There are a number of steps involved in calculating the required target level. See General Preamble at 13507-8 and Guidance on the Adjusted Base Year Emissions Inventory and the 1996 Target for the 15 Percent Rate of Progress Plans, Office of Air Quality Planning and Standards, U.S. EPA. EPA-452/R-92-005, October 1992 (“ROP Plan Guidance I”), pp. 9-17.

Step 1 -- Develop the 1990 Base Year Inventory

The baseline emission inventory is derived from the 1990 base year inventory required by CAA section 182(a)(1). Section 182(a)(1) requires the submittal of a comprehensive, accurate, and current inventory of actual emissions from all sources. This base year inventory must address both anthropogic and biogenic sources of VOC, nitrogen oxides (NOx), and carbon monoxide (CO) during the peak ozone season and include all point sources within a 25 mile-wide buffer ozone around the designated nonattainment area. General Preamble at 13502.

Step 2 -- Develop the 1990 ROP Base Year Inventory for the Nonattainment Area

The 1990 ROP base year inventory is developed by adjusting the base year inventory to remove 1) all biogenic emissions and 2) all emission from sources outside the nonattainment area.

1990 ROP base year inventory = 1990 base year inventory (biogenic sources + emissions from outside the nonattainment area)

Step 3 -- Develop the 1990 Adjusted Base Year Inventory

The 1990 adjusted base year inventory (which is also the baseline emissions inventory referred to in CAA section 182(b)(1)(B)) is calculated by removing from the 1990 ROP base year inventory any emissions reductions that will result from the FMVCP regulations promulgated by January 1, 1990 and from federal RVP regulations promulgated by January 1, 1990 or required by CAA section 211(h). In other words, the adjusted base year inventory must exclude any emission reductions that will accrue from motor vehicle fleet turn over and the new federal RVP standards applicable to the area between 1990 and 1996. To calculate the emissions reductions that will result from the FMVCP and RVP:



Actual 1990 emissions = 1990 VMT x MOBILE3 emission factors reflecting actual 1990 conditions

Adjusted 1990 emissions = 1990 VMT x MOBILE emission factors or 1996 with CAA measures including any RVP changes disabled and no changes to the I/M program or other fuel parameters from 1990 conditions.

Expected emission reductions from FMVCP and RVP =

Actual 1990 emissions - adjusted 1990 emissions

This amount is subtracted from the 1990 ROP base year inventory to get the 1990 adjusted year inventory from which the 15 percent target is calculated.

1990 adjusted base year inventory = 1990 ROP base year inventory Expected emission reductions from FMVCP and RVP

Step 4 -- Calculate the Required 15 Percent Reduction Target

To determine the 15 percent reduction target the 1990 adjusted base year inventory is multiplied by 0.15.

15 percent reduction target = 0.15 x 1990 adjusted base year inventory

Step 5 -- Calculate Total Reductions Needed by 1996

In this step, total emission reductions from the 1990 ROP base year inventory that are needed to meet the 15 percent demonstration are determined by summing 1) the 15 percent reduction calculated in Step 4, 2) the benefit of the FMVCP and RVP regulations calculated in Step 3, 3) and emission reductions from RACT and I/M corrections.

Emission reductions from any quantifiable corrections to required RACT rules are not creditable toward the 15 percent target. Methodology for calculating emission reductions from RACT rule corrections is found in Appendix B to ROP Plan Guidance I. Similarly, emission reductions from corrections to I/M programs are also not creditable. Corrections were needed if 1) the area’s I/M program did not meet EPA’s minimum standards or 2) the area’s program did not meet the standards of its then-current SIP. Methodology for calculating emission reductions from I/M corrections is found in Appendix C to ROP Plan Guidance I.

total reductions needed by 1996 = 15 percent reduction target +

3MOBILE4 was to be used initially and then MOBILE5a as it became available. ROP Plan Guidance I, p. 12.



Expected emission reductions from FMVCP and RVP + RACT corrections + I/M corrections

Step 6 -- Calculate the 1996 Target Level of Emissions

The final step is to calculate the 1996 target level of emissions by subtracting the total expected reductions by 1996 from the 1990 ROP base year inventory calculated in step 2 above.

1996 target level = Step 2 - Step 5

= 1990 ROP base year inventory -total reductions needed by 1996

To show that an area meets the 15 percent ROP requirements net of growth, projected 1996 total anthropogenic emissions including growth expected through 1996 have to be at or below this level. In calculating their projected 1996 total emissions, reductions from the FMVCP, RVP regulations, other federal measures including maximum achievable control technology (MACT) standards, RACT corrections, I/M corrections, and any additional controls the state may adopt can be included.

C. Post-1996 Emission Reductions Creditable to the 15 Percent ROP Demonstration

Although the November 15, 1996 deadline for demonstrating a 15 ROP has now passed, the 15 percent ROP requirement remains. Once a statutory deadline has passed and has not been replaced by a later one, the deadline then becomes as soon as possible. Delaney v. EPA, 898 F.2d 687, 691 (9th Cir. 1990). EPA has interpreted this requirement to be “as soon as practicable” (55 FR 36458, 36505 (September 9, 1990)); therefore, to demonstrate that the Phoenix area has met the CAA section 182(b)(1) requirement, it must be demonstrated that the 15 percent reduction will be achieved as soon as practicable by showing that the applicable implementation plan contains all VOC control measures that are practicable for the Phoenix area and that meaningfully accelerate the date by which the 15 percent level is achieved. See Note, Margo Oge, Director, Office of Mobile Sources and John Seitz, Director, Office of Air Quality Planning and Standards to Regional Division Directors; “Re: Date by which States Need to Achieve all the Reductions Needed for the 15% Plan from I/M and Guidance for Recalculation,” August 13, 1996 and Memorandum, John S. Seitz and Richard B. Ossias, Deputy Associate General Counsel to Regional Air Division Directors; “15 Percent VOC SIP Approvals and the ‘As Soon As Practicable’ Test;” February 12, 1997.

Reliance on post-1996 emission reductions in the 15 percent plan, however, requires that the 1996 target level of emission reductions be revised to remove the additional emission reductions from the FMVCP and federal RVP regulations between 1996 and the demonstration year (that is, the year that the 15 percent reduction will be achieved). See Memorandum, Gay MacGregor, Director, Regional and State Programs Division, OMS and Sally Shaver, Director, Air Quality Strategies and Standards Division, OAQPS to Regional Air Division Directors;



“Modeling 15% VOC Reduction(s) from I/M in 1999--Supplemental Guidance;” December 23, 1996.

The steps involved in calculating the revised target are for on-road motor vehicle controls:

Step 1 -- Calculate a 1990 adjusted base year on-road inventory for 1996:

1996 motor vehicle (MV) emission factor (MOBILE5a run for 1996 with CAA measures except Phase II RVP turned off) x 1990 vehicle miles traveled (VMT)

Step 2 -- Calculate a 1990 adjusted base year on road inventory for the demonstration:

Demonstration year MV emission factor (MOBILE5a run for demonstration year with CAA measures except RVP turned off) x 1990 VMT

Step 3 -- Calculate the difference between the two on-road inventories:

Uncreditable emission reductions from fleet turn over and RVP controls between 1996 and demonstration year

= Step 1 - Step 2

This amount is to be added to the emission reductions necessary to show 15 percent reduction.

Step 4 -- Calculate the projected 1996 on-road emissions inventory using demonstration year highway vehicle emission factors representing I/M test conditions and fuel characteristics in the demonstration year multiplied by 1996 VMT levels.

III. 15 Percent Rate of Progress Demonstration

A. 1990 Base Year Emission Inventory

1. State Inventory

The baseline from which the required reductions are determined for the 15 percent ROP plan is the 1990 base year emissions inventory. Arizona submitted a SIP revision containing the 1990 base year emissions inventory for the Maricopa County ozone nonattainment area on April 2, 1993. An amended submittal was made on November 15, 1993 as part of the 1993 Ozone Plan. Table 1 summarizes this inventory. EPA is proposing to fully approve this base year inventory as meeting both CAA section 182(a)(1) and EPA’s guidance for ozone emission inventories. EPA’s analysis of the 1990 base year emission inventory can be found in the memo in Appendix 1 of this TSD.



TABLE 1 METROPOLITAN PHOENIX 1990 BASE YEAR EMISSIONS INVENTORY

(METRIC TONS PER DAY)

SOURCE TYPE VOC NOX CO

Point Sources 25.6 70.9 13.8

Area Sources 111.8 7.4 3.9

On-Road Mobile 136.2 130.1 911.5

Non-Road Mobile 57.9 85.2 521.1

Biogenic 37.3 0 0

Total 368.8 293.6 1450.3 Source: “1990 Base Year Ozone Emission Inventory for the Maricopa County, Arizona, Nonattainment Area, Final Submittal”, Maricopa County Environmental Quality and Community Service Agency, July 1993 found in the 1993 Ozone Plan, Appendix B, Exhibit 1.

2. Adjustments to Base Year Inventory

For the purposes of its 15 percent demonstration, EPA has slightly modified the State’s base year inventory to reflect the delisting of perchloroethylene (used primarily as a drycleaning solvent) as a VOC (61 FR 4588 (February 7, 1996)), a revised version of EPA's MOBILE5a (March 29, 1993) on-road motor vehicle emission estimation model, and modified MOBILE5a inputs.

EPA has revised the base year inventory with the March 1993 version of MOBILE5a because it has used this version of the model in projecting future year on-road inventories, calculating the impact of the FMVCP and Phase I RVP controls, and in demonstrating the 15 percent reduction. The inputs to the model were also modified slightly from those used by the State in its base year inventory to assure consistency (where appropriate) between base year and



future year model runs.4 EPA also used local diesel sales fractions instead of national default diesel sales fractions.

These modifications that EPA do not affect the approvability of the State’s 1990 base year emissions inventory. The delisting of perchloroethylene occurred after the statutory due date for the inventory. In addition, states were not required to upgrade to the later version of MOBILE5a for their base year inventories. See Memorandum, Philip A. Lorang, Director, Emission Planning and Strategies Division, OMS to Regional Air Division Directors; “Release of MOBILE5a Emission Factor Model,” March 29, 1993. Finally, the use of local diesel sales fractions is preferred although not required.

As shown in Table 2, these modifications decreased the submitted base year area source inventory by 1.2 metric tons per day and the on-road mobile inventory by 0.6 metric ton per day for a total decrease in the inventory of 1.8 metric tons per day.

TABLE 2 ADJUSTED METROPOLITAN PHOENIX 1990 BASE YEAR EMISSIONS INVENTORY

(VOC EMISSION IN METRIC TONS PER DAY)

SOURCE TYPE STATE

INVENTORY ADJUSTMENT

ADJUSTED INVENTORY

Point Sources 25.6 0 25.6

Area Sources 111.8 -1.2 110.6

On-Road Mobile 136.2 -0.6 135.6

Non-Road Mobile 57.9 0 57.9

Biogenic 37.3 0 37.3

Total 368.8 -1.8 367

4EPA noted in the proposal that its principle MOBILE5a modification was to use minimum and maximum daily temperatures to calculate temperature corrections to the VOC exhaust emissions, hot soak evaporative emissions, and resting loss emissions instead of a single ambient temperature as was done by Arizona and that, although it does not recommend the use of a single ambient temperature to calculate these emissions, the impact on the base year inventory in this case was so slight (less than 0.6 metric tons per day out of an inventory of 136 metric tons per day or less than 0.5 percent) as to not constitute grounds for disapproval. 63 FR 3689, footnote 5. This footnote was in error. Arizona used minimum and maximum daily temperatures in its MOBILE runs and EPA inadvertently used a single temperature. Because the difference was so slight and the same approach was used consistently from base year and future year inventories, the use of a single temperature value does not invalidate the conclusion that the Phoenix area has in place sufficient reductions to show the required 15 percent ROP.



To calculate the base year on-road inventory, EPA made two MOBILE5a runs, one assuming the State’s 1990 I/M program and one assuming no I/M. The input and output files for these runs are in Appendix 2. Composite on-road emission factors were then calculated assuming 88 percent of the fleet was subject to I/M and 12 percent was not. The composite emission factors are given in Appendix 2. The total inventory, by vehicle type and road class, is shown in Table 3.

B. 15 Percent ROP Target Calculations

Step 1 -- 1990 Base Year Emission Inventory

The 1990 base year emission inventory (with the minor adjustments discussed above) is given in Table 4.



TABLE 3 ADJUSTED METROPOLITAN PHOENIX 1990 ON-ROAD VOC EMISSIONS INVENTORY

Vehicle Class

Roadway Type

Speed (MPH)

Factor (grams/mile)

DVMT (miles/day)

Emissions (kg/day)

Vehicle Class

Roadway Type

Speed (MPH)

Factor (grams/mile)

DVMT (miles/day)

Emissions (kg/day)

LDGV

VMT fraction:

0.649

Urban LDGT2

VMT fraction:

0.085

Urban

Fwys & Expwys 55.7 2.08 6,231,162 8398 Fwys & Expwys 55.7 3.22 6,231,162 1706

Principal art. 30.3 2.82 12,674,890 23196 Principal art. 30.3 4.17 12,674,890 4497

Minor art. 30.3 2.82 3,492,062 6391 Minor art. 30.3 4.17 3,492,062 1239

Collectors 25 3.19 1,408,728 2920 Collectors 25 4.70 1,408,728 563

Local roads 20 3.69 4,378,342 10477 Local roads 20 5.41 4,378,342 2013

Rural Rural




Collectors 30 2.84 904,098 1665 Collectors 30 4.20 904,098 323


LDGT1

VMT fraction:

0.158

Urban HDGV

VMT fraction:

0.035

Urban






Rural Rural






Total: 100283 Total: 27622



TABLE 3 -- CONTINUED ADJUSTED METROPOLITAN PHOENIX 1990 ON-ROAD VOC EMISSIONS INVENTORY

Vehicle Class

Roadway Type

Speed (MPH)

Factor (grams/mile)

DVMT (miles/day)

Emissions (kg/day)

Vehicle Class

Roadway Type

Speed (MPH)

Factor (grams/mile)

DVMT (miles/day)

Emissions (kg/day)

LDDV

VMT fraction:

0.007

Urban HDDV

VMT fraction:

0.057

Urban






Rural Rural






LDDT

VMT fraction:

0.002

Urban MC

VMT fraction:

0.006

Urban






Rural Rural






Total: 355 Total: 7305

Grand total: 135565



TABLE 4 ADJUSTED METROPOLITAN PHOENIX

1990 BASE YEAR EMISSIONS INVENTORY (VOC EMISSION IN METRIC TONS PER

DAY)

SOURCE TYPE INVENTORY

Point Sources 25.6

Area Sources 110.6

On-Road Mobile 135.6

Non-Road Mobile 57.9

Biogenic 37.3

Total 367

Step 2 -- 1990 ROP Base Year Inventory for the Nonattainment

The 1990 ROP base year inventory is developed by adjusting this base year inventory to remove 1) all biogenic emissions and 2) all emissions from sources outside the nonattainment area (Table 5).

1990 ROP base year inventory = 1990 base year inventory (biogenic sources + emissions from outside the nonattainment area)



TABLE 5 PHOENIX 1990 ROP BASE YEAR EMISSIONS INVENTORY


ADJUSTMENT (MT/D)

ROP BASE YEAR INVENTORY (MT/D)

1990 Base year inventory 367.0

Stationary sources outside of the nonattainment area

- 1.8

Biogenic emissions - 37.3

1990 nonattainment area base year anthropogenic inventory

327.9

The figure for sources outside the nonattainment area comes from “1990 Base Year Inventory,” p. 2-31: 4013 lb per day/2204 lb per metric ton = 1.8 metric tons per day

Step 3 -- 1990 Adjusted Base Year Inventory

The 1990 adjusted base year inventory (which is also the baseline emissions inventory referred to in CAA section 182(b)(1)(B)) is calculated by removing from the 1990 ROP base year inventory any emissions reductions that will result from the FMVCP regulations promulgated by January 1, 1990 and from federal RVP regulations promulgated by January 1, 1990 or required by CAA section 211(h). To calculate the emissions reductions that will result from the FMVCP and RVP:

Actual 1990 emissions = 1990 VMT x MOBILE emission factors reflecting actual 1990 conditions

Adjusted 1990 emissions = 1990 VMT x MOBILE emission factors reflecting 1996 year conditions with CAA measures including any RVP changes disabled and no changes to the I/M program or other fuel parameters from 1990 conditions.

Expected emission reductions from FMVCP and RVP =

Actual 1990 emissions - adjusted 1990 emissions



TABLE 6 EXPECTED EMISSION REDUCTIONS FROM FMVCP

AND FEDERAL RVP STANDARDS -- ON-ROAD ONLY (VOC EMISSION IN METRIC TONS PER DAY)

YEAR ADJUSTED 1990

EMISSIONS 1990 ACTUAL

EMISSIONS

EXPECTED EMISSION REDUCTIONS FROM FMVCP AND RVP ON-ROAD ONLY

1996 90.2 135.6 45.4

1997 87.3 135.6 48.3

1998 86.8 135.6 48.8

1999 85.2 135.6 50.4

Appendix 3 contains sample MOBILE5a input and output files, the composite emission factors, and the total on-road inventory, by vehicle type and road class.

Further adjustments to the inventory are necessary because of the effect of RVP controls on emissions from gasoline-powered non-road engines. These adjustments are summarized in Table 7 and are discussed in more detail in Section III.C.2. below. Also shown in Table 7 are the uncreditable reductions from the FMVCP and RVP changes between 1996 and later years.

TABLE 7 EXPECTED EMISSION REDUCTIONS FROM FMVCP

AND FEDERAL RVP STANDARDS TOTAL FOR ON AND NON-ROAD SOURCES (VOC EMISSION IN METRIC TONS PER DAY)

YEAR ON-ROAD NON-ROAD TOTAL YEAR - 1996 DIFFERENCE

1996 45.4 2.0 47.4 -

1997 48.3 2.0 50.3 2.9

1998 48.8 2.0 50.8 3.4

1999 50.4 2.0 52.4 5.0



The expected emission reductions from FMVCP and federal RVP limits in 1996 are subtracted from the 1990 ROP base year inventory to get the 1990 adjusted year inventory from which the 15 percent target is calculated.

1990 adjusted base year inventory = 1990 ROP base year inventory Expected emission reductions from FMVCP and RVP

The results from this calculation for the Phoenix area are shown in Table 8.

TABLE 8 PHOENIX ADJUSTED BASE YEAR INVENTORY (VOC EMISSION IN METRIC TONS PER DAY)

YEAR 1990 ROP BASE

YEAR INVENTORY

TOTAL REDUCTIONS FROM FMVCP AND

RVP

ADJUSTED BASE YEAR INVENTORY

1996 327.9 47.4 280.5

Step 4 -- Calculate the Required 15 Percent Reduction Target

To determine the 15 percent reduction target the 1990 adjusted base year inventory is multiplied by 0.15.

15 percent reduction target = 0.15 x 1990 adjusted base year inventory

The result of this calculation for the Phoenix area is given in Table 9.

TABLE 9 PHOENIX 15 PERCENT REDUCTION TARGET (VOC EMISSION IN METRIC TONS PER DAY)

YEAR 1990 ADJUSTED BASE

YEAR INVENTORY 15 PERCENT TARGET

1996 280.5 42.1

Step 5 -- Calculate Total Reductions Needed by 1996

In this step, total emission reductions from the 1990 ROP base year inventory that are needed to meet the 15 percent demonstration are determined by summing 1) the 15 percent reduction calculated in Step 4, 2) the reductions from the uncreditable FMVCP and RVP



regulations occurring between 1990 and 1996, 3) the reductions from the uncreditable FMVCP and RVP regulations occurring between 1996 and the demonstration year and 4) emission reductions from RACT and I/M corrections.

The estimated emission reductions from the RACT corrections are shown in Table 10. No I/M correction was needed for the Phoenix area.

TABLE 10 EMISSION REDUCTIONS FROM RACT

CORRECTIONS (VOC EMISSIONS IN METRIC TONS PER DAY)

MEASURE REDUCTION

Rule 337 - Graphic Arts 0.37

Rule 350 - Storage of Organic Liquids at Bulk Terminals

0.06

Rule 353 - Transfer of Gasoline into Stationary Storage Dispensing Tanks

0.02

Rule 336 - Surface Coating Operations

0.00

Rule 338 - Semiconductor Manufacturing

1.21

Rule 341 - Metal Casting 0.68

Total 2.3 Source: 1993 Ozone Plan, Appendix B, Exhibit 2, Attachment 4

Total reductions needed by the demonstration year are calculated as follows:

total reductions needed = 15 percent reduction target + Expected emission reductions from FMVCP and RVP (1990-1996) + expected emission reductions from FMVCP and RVP (1996 - demonstration year) + RACT corrections + I/M corrections

The results from this calculation for the Phoenix area shown in Table 11.



TABLE 11 TOTAL REDUCTIONS NEEDED TO SHOW 15 PERCENT ROP


YEAR FMVCP AND

RVP (1990-1996)

FMVCP AND RVP

(1996-YEAR) 15 PERCENT

RACT TOTAL

REDUCTION NEEDED

1996 47.4 0 42.1 2.3 91.8

1997 47.4 2.9 42.1 2.3 94.7

1998 47.4 3.4 42.1 2.3 95.2

1999 47.4 5.0 42.1 2.3 96.8

Step 6 -- Calculate the 1996 Target Level of Emissions

The final step is to calculate the demonstration year target level of emissions by subtracting the total needed reductions by the demonstration year from the 1990 ROP base year inventory calculated in step 2 above.

target level = Step 2 - Step 5

= 1990 ROP base year inventory -total reductions needed

The results from this calculation for the Phoenix area are shown in Table 12.

TABLE 12 TARGET LEVEL OF EMISSIONS NEEDED TO SHOW 15 PERCENT ROP


YEAR 1990 ROP BASE YEAR

INVENTORY TOTAL REDUCTIONS

NEEDED TARGET LEVEL OF

EMISSIONS

1996 327.9 91.8 236.1

1997 327.9 94.7 233.2

1998 327.9 95.2 232.7

1999 327.9 96.8 231.1



C. Control Measure Evaluation

1. Stationary and Area Source Measures

Stationary point and area sources include a wide variety of non-mobile emissions sources from stationary combustion sources such as boilers to emissions from refueling of automobiles. The primary sources of emissions from stationary sources in the Phoenix area are gasoline-handling operations and the evaporation of VOC-containing solvents from paints, other surface coatings, consumer products, and pesticides.

Maricopa County Environmental Services Department (MCESD) has adopted a number of rules to control emissions from many stationary source categories. In addition, the Arizona Department of Weights and Measures has adopted Stage II vapor recovery for service stations to control emissions from vehicle refueling. Finally, there are also several proposed national rules that regulate manufacturers of solvent-containing materials such as consumer products and autobody refinishing paints.

As a starting point for analyzing which control measures to include in its 15 percent demonstration, EPA reviewed Arizona’s submitted 15 percent plan for the Phoenix metropolitan area. The State’s plan explicitly relied on a number of the stationary source controls measures. Many of these measures have been adopted as rules and have been separately submitted as SIP revisions. The State’s 15 percent plan also relied less explicitly on a number of other measures that were adopted either after 1990 or had compliance deadlines after 1990 but prior to submittal of the 15 percent plan. These measures include the State’s Stage II vapor recovery rules and the County’s architectural coatings rule. In the State's plan emission reductions from these measures were included in projecting emissions to 1996 rather than explicitly included in demonstrating the 15 percent. While the State’s approach is acceptable, EPA has chosen to explicitly identify these measures and included their emission reductions in the 15 percent demonstration it has developed for the area.

Table 13 identifies all major stationary source control measures submitted by the State and describes their current SIP approval status. Table 14 identifies which measures are creditable to the 15 percent demonstration and Table 15 provides emission reduction calculations for each measure. Finally, Table 16 summarizes the creditable emission reductions for each measure and Table 17 presents the 1990 base year and 1996 projected, controlled inventory for stationary point and area sources.



TABLE 13 SIP APPROVAL STATUS OF STATIONARY SOURCE MEASURES SUBMITTED BY ARIZONA

MEASURE CITE DESCRIPTION STATUS

Wood coating Addendum, p. 2-13 H.B. 2001, section 4 (A.R.S. 11-874(1))

MCESD Rule 342--Coating Wood Furniture and Fixtures and Rule 346-Coating Wood Millwork

Requires Maricopa County to develop, implement, enforce rules regulating VOC emission from the wood coating industry sector by a minimum of 25% from 1990 baseline emissions by 11/15/95.

Rule 342--Coating Wood Furniture and Fixtures (adopted 4/3/96, amended 11/20/96) SIP status: submitted, approved 2/9/98 (63FR6489) Rule 346--Coating Wood Millwork (adopted 4/3/96, amended 11/30/96) SIP status: approved 2/9/98 (63FR6489)

Commercial Addendum, p. 2-13 Requires Maricopa County to develop, implement, Rule 343--Commercial Bread Bakeries bakeries H.B. 2001, section 4

(A.R.S. 11-874(2)) MCESD Rule 343-Commercial Bread Bakeries

enforce a rule regulating VOC emission from the commercial bakery industry sector by a minimum of 30% from 1990 baseline emissions by 11/15/95.

(adopted 2/15/95) SIP status: Approved 3/17/97 (62FR12544)

Windshield Addendum, p. 2-14 Requires Maricopa County to develop, implement, Rule 344--Automotive Windshield Washer Fluid wiper fluids H.B. 2001, section 4

(A.R.S. 11-874(3)) MCESD Rule 344-Automotive Windshield Washer Fluid

enforce a rule requiring the reformulation of windshield wiper fluid that contains a concentration of not more than 30% VOC or any other component by 11/15/95.

(adopted 2/15/94, revised 4/3/96) SIP status: submitted, no action

Consumer and Addendum, p. 2-14 If triggered, requires Maricopa County to adopt SIP status: submitted, no action commercial H.B. 2001, section 4 EPA’s CTG for the consumer and commercial No rule adopted. No CTG. products (A.R.S. 11-874(3)) products. Proposed national rule to regulate 24 (including (Contingency windshield wiper fluid) categories of consumer products measure) published on 4/2/96 (61FR14531). Final rule expected

by 8/15/98 with implementation in late 1998.



TABLE 13 - CONTINUED SIP APPROVAL STATUS OF STATIONARY SOURCE MEASURES SUBMITTED BY ARIZONA


CTG adoption (Contingency measure)

Addendum, p. 2-16 H.B. 2001, section 4 (A.R.S. 11-872)

MCESD Rule 336--Surface Coating Operations

Contingency measure triggered by SIP call. If triggered, requires the adoption of any CTG within 60 days of its issuance by EPA (trigger is a SIP call).

SIP status: submitted, no action

Aerospace CTG Measure converted to 15% ROP measure, see Modeling Attainment Demonstration, p. 3-7.

Proposed but no final CTG. NESHAP proposed. Rule 336--Surface Coating Operations (adopted 7/13/88, latest revision 6/19/96) SIP status: Revision submitted 2/26/97, limited approval 2/9/98 (63FR6487)


MCESD Rule 337--Graphic Arts

Graphic arts CTG Measure converted to 15% ROP measure, see Modeling Attainment Demonstration, p. 3-7.

No CTG issued. ACT issued June 1994 Rule 337--Graphic Arts (Adopted 4/6/92, latest revision 11/20/96) SIP status: 4/6/92 version approved on 9/5/95 (60FR46024), revision submitted, 3/4/97, approved 2/9/98 (63FR6489)

MCESD Rule 345--Vehicle Refinishing National rule proposed on April 30, 1996 (61FR19005) and reproposed on December 15, 1997 (62FR67784)

Auto refinishing CTG No CTG issued. ACT issued April 1994. Rule 345--Vehicle Refinishing (Adopted 2/15/95, amended 11/20/96) SIP status: submitted, 3/4/97, no action National rule proposed April 30, 1996 (61FR19005) and December 30, 1997 (62FR67784). Final rule expected by 8/15/98 with implementation in late 1998.

MCESD Rule 342--Coating Wood Furniture and Fixtures and Rule 346-Coating Wood Millwork

Coating Wood Furniture and Fixtures CTG Measure converted to 15% ROP measures, see Modeling Attainment Demonstration, p. 3-7.

CTG issued May 20, 1996, rules revised. See discussion under wood coatings above.



TABLE 13 - CONTINUED SIP APPROVAL STATUS OF STATIONARY SOURCE MEASURES SUBMITTED BY ARIZONA


Graphic arts Addendum, p. 2-12 H.B. 2001, section 4 (A.R.S. 11-873)

MCESD Rule 337--Graphic Arts

Maricopa County is to develop, implement, enforce a rule regulating emissions from the graphic arts industry sector, requires enhanced enforcement of this rule through increased frequency and targeting of inspections, increased sampling frequency, and use of portable analyzers or any other techniques.

Rule 337--Graphic Arts (Adopted 4/6/92, latest revision 11/20/96) SIP status: 4/6/92 version approved on 9/5/95 (60FR46024) revision submitted, 3/4/97 ,approved 2/9/98 (63FR6489) No action on improved rule effectiveness.

Architectural and Addendum, p. 2-12 Maricopa County is to develop, implement, enforce a Rule 335--Architectural coatings (adopted 7/13/88) industrial H.B. 2001, section 4 rule regulating emissions from the architectural and SIP status: Approved 1/6/92 (57FR354) coatings (A.R.S. 11-873)

MCESD Rule 335-Architectural coatings and Rule 336--Surface Coating Operations

industrial coatings industry sector, requires enhanced enforcement of this rule through increased frequency and targeting of inspections, increased sampling frequency, and use of portable analyzers or any other techniques.

Rule 336--Surface Coating Operations (adopted 7/13/88, latest revision 6/19/96) SIP status: Submitted, limited approval 2/9/98 (63FR6487) No action on improved rule effectiveness.

Highway Addendum, p. 2-12 Maricopa County is to develop, implement, enforce a Rule 335--Architectural coatings (adopted 7/13/88) markings H.B. 2001, section 4

(A.R.S. 11-873)

MCESD Rule 335-Architectural coatings

rule regulating emissions from the highway markings industry sector, requires enhanced enforcement of this rule through increased frequency and targeting of inspections, increased sampling frequency, and use of portable analyzers or any other techniques.

(section 305, traffic coating limit effective 7/13/91) SIP status: Approved 1/6/92 (57FR354) No action on improved rule effectiveness. National AIM rule proposed more stringent limits on traffic coatings. See 61FR12544 (June 25, 1996)

Bulk plants and Addendum, p. 2-12 Maricopa County is to develop, implement, enforce a Rule 350--Storage of Organic Liquids at Bulk Plants and terminals H.B. 2001, section 4

(A.R.S. 11-873)

MCESD Rule 350--Storage of Organic Liquids at Bulk Plants and Terminals

rule regulating emissions from bulk plants and terminals, requires enhanced enforcement of this rule through increased frequency and targeting of inspections, increased sampling frequency, and use of portable analyzers or any other techniques.

Terminals (adopted 7/13/88, revised 4/6/92) SIP status: revision approved 9/5/95 (60FR

46024) No action on improved rule effectiveness.



TABLE 13 - CONTINUED SIP APPROVAL STATUS OF STATIONARY SOURCE MEASURES SUBMITTED ARIZONA


Tank truck Addendum, p. 2-12 Maricopa County is to develop, implement, enforce a Rule 351--Loading of Organic Liquids (adopted 7/13/88, loading H.B. 2001, section 4 rule regulating emissions from tank truck loading revised 4/6/92, latest revision 2/15/95) operations (A.R.S. 11-873)

MCESD Rule 351--Loading of Organic Liquids

operations, requires enhanced enforcement of this rule through increased frequency and targeting of inspections, increased sampling frequency, and use of portable analyzers or any other techniques.

SIP status: 4/6/92 revision approved 9/5/95 (60FR12544); 2/15/95 version submitted, approved 2/9/98 (63FR6489) No action on improved rule effectiveness.

Stage I/II vapor MCESD Rule 353 - Requires the installation of certified Stage I vapor Rule 353--- Transfer of Gasoline into Stationary Storage recovery Transfer of Gasoline into

Stationary Storage Dispensing Tanks


recovery equipment at service stations.

Requires the director of Weights and Measures to adopt rules to enhance enforcement of state II vapor recovery program. Enhanced enforcement of this rule may be done through increased frequency and targeting of inspections, increased sampling frequency, and use of portable analyzers or any other techniques.

Dispensing Tanks (adopted 7/13/88, revised 4/6/92) SIP status: Approved 2/1/96 (61FR3578) Stage II vapor recovery regulations were approved on 11/1/94 (59FR54521). Stage I & II requirements found in A.R.S. title 41, chapter 15, article 7 (A.R.S. §§41-2131 through 2133) and A.A.C. R4-31-901 through R4-31-910. Both require the sole use of CARB certified vapor recovery equipment, see A.R.S. §41-2132(A) and 41R431-904(A). No new rules adopted by ADW&M; no action on improved rule effectiveness.

Solvent cleaning MCESD Rule 331 -Solvent Cleaning

Reduce emissions from degreasing operations. MCESD Rule 331 -- Solvent Cleaning (adopted 7/13/88, revised 6/22/92, latest revision 6/19/96) SIP status: Approved 2/1/96 (61FR3578), 6/19/96 version submitted, approved 2/9/98 (63FR6489)

Solvent cleaning VEOP, B-23 Requires Maricopa County to develop, implement, No rule adopted. Rule under development. operations H.B. 2237, section 3

(A.R.S. 11-874(4)) enforce a rule regulating VOC emission from the solvent cleaning operations including the use of nonaqueous solvents. The regulations may include lower VOC content solvents or low VOC aqueous material substitutions.



TABLE 14 CREDITABILITY OF STATIONARY SOURCE MEASURES

MEASURE CITE CREDITABILITY

Wood coating MCESD Rule 342-Coating Wood Furniture and Fixtures MCESD Rule 346-Coating Wood Millwork

Rules 342 & 346 have phased compliance: 5/3/96 for sources >= 50 tpy and 11/15/96 for sources < 50 tpy (Rule 342, section 401 and Rule 346, section 401).

Emission reductions from implementation through 11/15/96 are fully creditable.

Commercial bakeries MCESD Rule 343-Commercial Bread Bakeries

Rule 343 required full compliance by 11/15/95.

Emission reductions from the rule are fully creditable in 1996.

Windshield wiper fluids MCESD Rule 344-Automotive Windshield Washer

Rule 334 is not SIP approved.

Emission reductions from the Rule 344 are not creditable toward 15%. Emission reductions from windshield wiper fluid included in national consumer product rule.

Consumer and commercial products

Addendum, p. 2-14 H.B. 2001, section 4 (A.R.S. 11-874(3))

national rule: proposed 4/2/96 (61FR14531).

No rule adopted. Proposed national rule to regulate 24 categories (including windshield wiper fluids) of consumer products published on 4/2/96 (61FR14531).

National rule creditable at 20% of effected source categories per Memorandum, John S. Seitz, Director, OAQPS to Regional Air Division Directors; “Regulatory Schedule for Consumer and Commercial Products under Section 182(e) of the Clean Air Act;” June 22, 1995.

CTG adoption (STATE CONTINGENCY MEASURE, partially converted to 15% plan measures)


No rules adopted.

No creditable emission reductions.

MCESD Rule 336-Surface Coating Operations

Rule 336 required compliance by 9/21/92 (section 401).

Emission reductions from the rule are fully creditable in 1996.

MCESD Rule 337-Graphic Arts

See below under graphic arts.



TABLE 14 - CONTINUED CREDITABILITY OF STATIONARY SOURCE MEASURES


CTG adoption (CONTINGENCY MEASURE, partially converted to 15% plan measures)

MCESD Rule 345-Vehicle Refinishing

National rule proposed on April 30, 1996 (61 FR 19005) and reproposed on December 15, 1997 (cite)

Compliance required by 11/15/95 (section 401). Rule is not SIP approved

No creditable emission reductions from Rule 345. In lieu of local rule, national rule for this category is creditable at 37% reduction, per Memorandum, John S. Seitz, Director, OAQPS to Regional Air Division Directors; “Credit for the 15 Percent Rate-of-Progress Plans for Reductions from the Architectural and Industrial Maintenance Coating Rule and the Autobody Refinishing Rule;” November 29, 1994.

MCESD Rule 342-Coating Wood Furniture and Fixtures MCESD Rule 346-Coating Wood Millwork

See above under wood coatings.

Graphic arts MCESD Rule 337-Graphic Arts

Limits in Rule 337 were effective 5/3/96 (section 401).

Emission reductions from the rule are fully creditable in 1996. No creditable emission reductions from improved RE.

Architectural and industrial coatings

MCESD Rule 335-Architectural coatings

All limits in Rule 335 effective by 7/13/91 (Section 300)

Emission reductions from the rules are fully creditable in 1996. No creditable emission reductions from improved RE.

Highway markings MCESD Rule 335-Architectural coatings

Rule 335, section 305, traffic coating limit was effective 7/13/91

Emission reductions from the rule for highway markings are fully creditable in 1996. No creditable emission reductions from improved RE.

Bulk plants and terminals

MCESD Rule 350-Storage of Organic Liquids at Bulk Plants and Terminals

Rule 350 limits were effective 5/3/96 (section 401).




TABLE 14 - CONTINUED CREDITABILITY OF STATIONARY SOURCE MEASURES


Tank truck loading operations

MCESD Rule 351-Loading of Organic Liquids

Rule 351 required compliance by 4/30/96 (section 402)


Stage I/ II vapor recovery

MCESD Rule 353 -Transfer of Gasoline into Stationary Storage Dispensing Tanks

A.R.S. 41-2134

A.R.S. 41-2134 required compliance by 11/15/94 (A.R.S. 41-2132(I)).

Emission reductions are fully creditable from Stage II. Stage I credit from addition of pressure vacuum valves.

Degreasing Rule 331 - Solvent Cleaning

Rule 331 required compliance prior to November 15, 1996.

Emission reductions can be credited but are assumed in the base line projections.

Industrial Solvent cleaning operations

VEOP, B-23 H.B. 2237, section 3 (A.R.S. 11-874(4))

No rule adopted by County.

No creditable emission reductions.



TABLE 15 EMISSION REDUCTIONS FROM STATIONARY SOURCE RULES

MEASURE RULE CITES FOR EMISSION REDUCTION

CALCULATIONS EMISSION REDUCTION CALCULATIONS

Wood MCESD Rule 342- Base year inventory: 1990 Base Year 1990 Point only: 5079 + 4167 ppd + 715 ppd = 9961 ppd coating Coating Wood

Furniture and Fixtures MCESD Rule 346-Coating Wood Millwork

Inventory, pp. 2-46 & 2-47 + missing source 6027. Growth surrogate for wood coatings is employment/HAPs/prev with a growth factor from 1990-1996 of 0.95, 1996 Baseline Projection Inventory, p. 52 (source 6060). Revised growth/control factors are from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 2.

Baseline growth factor assumed a 5% reduction from HAPs/P2 controls, w/o this control growth factor is 1.00 Control is 25% with a 80% rule effectiveness

1996 emissions reductions = 9961 ppd x 1.00 x (0.25x0.80) = 1992 ppd or 0.91 mt/d

Does not include any reductions from area source wood coaters. Point sources covered are: 6001, 6045, 6072, 6055, 6060, 6061, 6046, 6026, 6002, 6068, 6017, 6025, 6027, 6034, 6042, 6041, 6074, 6075, 6048, 6053, 6057, 6054, 6059, and 6067

Commercial MCESD Rule 343- Base year inventory: 1990 Base Year 1685 ppd, all point sources only (1990) bakeries Commercial Bread

Bakeries Inventory, p. 2-22. Growth surrogate for bakeries is employment/food with a growth factor from 1990-1996 of 1.13, 1996 Baseline Projection Inventory, p. 55 (example source 8018). Revised growth/control factors are from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 1.

1136 ppd from points 8018 and 8019 (1990) Revised growth factor: control is 30% with a 80% rule effectiveness Rule 343 applies only to two largest bakeries (8018 and 8019) at 81% reduction for a category wide control level of 30% from point sources.

1996 emissions reductions = 1136 ppd x 1.13 x (0.81x0.80) = 831 ppd or 0.38 mt/d



TABLE 15 - CONTINUED EMISSION REDUCTIONS FROM STATIONARY SOURCE RULES



Consumer and commercial products

Credit allowed per Seitz memo “Regulatory Schedule for Consumer and Commercial Products under Section 183(e) of the Clean Air Act,” 6/22/95

National rule proposed on April 2, 1996 (61FR 14531)

Base year inventory: 1990 Base Year Inventory, p. 3-56.

Reduction estimates: Memorandum, John S. Seitz, Director, OAQPS to Regional Air Division Directors; “Regulatory Schedule for Consumer and Commercial Products under Section 182(e) of the Clean Air Act;” June 22, 1995.

Growth surrogate for consumer products category is population. Population growth factor from 1990-1996 is 1.16, 1996 Baseline Projection Inventory, p.61.

Inventory gives total per capita figure for source category is 6.3 lb per capita per year. National rule regulates 3.9 lb per capita per year at 20 percent control.

Total percent control for category is (3.9 x 0.2)/6.3 = 12.4%

1990 population was 2,180,638

1996 emissions reductions: = 2,189,638 x 1.16 x 6.3 lb per capita per year x 0.124/365 day/year = 5436 ppd or 2.5 mt/d






Aerospace MCESD Rule 336-Surface Coating Operations

Base year inventory: 1990 Base Year Inventory, pp. 2-21 to 2-31. Growth surrogate for aerospace sources varies by source, see calculations and Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 12. ID of sources subject to rule and revised growth/control factors are from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 6.

Point source (6540, 6008, 6043, 4452, 4453, 6069, 6050) = 783 ppd + 137 ppd + 322 ppd + 138 ppd + 433 ppd + 184 ppd + 109 ppd = 2106 ppd (1990), growth factor is 1.00 (employment/manufacturing), no reduction from HAPS/P2 program assumed Assumed 67% of emissions are from hand wiping and cleaning with an emission reduction of 80% and rule effectiveness of 80% Estimated reduction = 2106 ppd x 1 x (0.67x0.80x0.80) = 903 ppd Point sources (1209) = 374 ppd (1990), growth factor is 1.00 (Luke), same assumptions re: emission reduction as above Estimated reduction = 374 ppd x 1 x (0.67x0.80x0.80) = 160 ppd Point sources (6024) = 79 ppd (1990), growth factor is 1.05 (transportation), same assumptions re: emission reduction as above Estimated reduction = 79 ppd x 1.05 x (0.67x0.80x0.80) = 36 ppd Point sources (1218) = 225 ppd (1990), growth factor is 0.65 (AV forecasts), same assumptions re: emission reduction as above Estimated reduction = 225 ppd x 0.65 x (0.67x0.80x0.80) = 63 ppd Total reduction = 1162 ppd or 0.53 mt/d






Graphic arts MCESD Rule 337-Graphic Arts

List of sources subject to rule is from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 5. Base year inventory: 1990 Base Year Inventory, pp. 2-16 thru 2-20 (point) and 3-51 (area). Growth surrogate for graphic sources varies by source, see calculations and Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, pp. 17 - 18. Revised growth/control factors are from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 4 -5.

Emission reductions come from expansion of the rule to offset lithography operations. Area sources = 7,868 ppd (1990), growth factor 1.02 (employment/printing & publishing) Point source (5002) = 88 ppd, growth factor is 1.34 (employment/business services) Point sources (5003, 5004, 5005, 5014, 5011) = 72 ppd + 89 ppd + 161 ppd + 185 ppd + 185 ppd = 692 ppd (1990), growth factor is 1.02 (employment/printing & publishing) Point sources (5013) = 90 ppd (1990), growth factor is 1.0 (employment/manufacturing) Point source (newspapers) (5008, 5009) = 117 ppd + 85 ppd = 202 ppd (1990), growth factor is 1.02 (employment/printing & publishing) Point sources (5006, 5017, 5010, 5012) = 167 ppd + 497 ppd + 368 ppd + 174 ppd = 1206 ppd (1990), growth factor is 1.02 (employment/printing & publishing) Point sources (5016) = 16 ppd (1990), growth factor is 1.0 (employment/manufacturing)

Area sources: estimated that 50% of emissions are from clean up and 50% from inks Control effectiveness = 71% from IPA fountain solutions and 70% from clean up, rule effectiveness = 80% (p. 4 of Air Quality Bill ) Emission reduction = 7,868 ppd x 1.02 [(0.5x0.8x.71) + (0.5x0.8x0.70) = 4526 ppd Point sources (other litho): estimated that 35% of emissions are from clean up with a control effectiveness of 70%, rule effectiveness = 80% (p. 4 of Air Quality Bill Emission reductions (5002) = 88 ppd x 1.34 (0.80x0.70x0.35) = 17 ppd






Graphic arts MCESD Rule 337- List of sources subject to rule is from Air Emission reductions (5003, 5004, 5005, 5014, 5011)- continued Graphic Arts Quality Bill Based 1996 and 2005

Projection Growth Factors for VOC Emissions, p. 5. Base year inventory: 1990 Base Year Inventory, pp. 2-16 thru 2-20 (point) and 3-51 (area). Growth surrogate for graphic sources varies by source, see calculations and Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, pp. 17 - 18. Revised growth/control factors are from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 4 -5.

= 692 ppd x 1.02 (0.80x0.70x0.35) = 138 ppd Emission reductions (5013) = 90 ppd x 1.02 (0.80x0.70x0.35) = 18 ppd

Point sources (newspapers): estimated that 80% of emissions are from clean up with a control effectiveness of 70%, rule effectiveness = 80% (p. 5 of Air Quality Bill) Emission reductions (5008, 5009) = 202 ppd x 1.02(0.80x0.70x0.80) = 92 ppd Point sources (5006, 5010, 5017, 5012, 5016): estimated that 35% of emissions are from clean up with a control effectiveness of 70%, rule effectiveness = 80%; estimated 65% from operations, no additional control assumed (no reduction from HAPs/P2 program or rule effectiveness improvements) (p. 5 of Air Quality Bill) Emission reductions (5006, 5010, 5017, 5012)

= 1206 ppd x 1.02x(0.80x0.35x0.7) = 241 ppd Point source (5016)

= 178 ppd x 1.00(0.80x0.35x0.7) = 35 ppd

Total: 5067 ppd or 2.30 mt/d






Degreasing MCESD Rule 331 -Solvent Cleaning

Base year inventory: 1990 Base Year Inventory, p 3-46.

Growth surrogate for area sources is population. Population growth factor from 1990-1996 is 1.16 (AMS 24-15000-000), 1996 Baseline Projection Inventory, p. 60. Control factors are from 1996 Baseline Projection Inventory, p. 10.

Reductions are assumed to be from area sources only.

1990 area sources = 18,740 ppd

Control on cold cleaning is 55 percent, with rule effectiveness of 80 percent impacting 85.7 percent of cold cleaning operations which comprise 96 percent of degreasing emissions

1996 reduction = 18,740 x 0.55 x 0.80 x 0.96 x 0.857 = 6783 ppd = 3.08 mt/d

Auto National rule proposed Base year inventory: 1990 Base Year Seitz memo allows at 37% reduction from current emissions, 100% rule refinishing on April 30, 1996 (61

FR 19005) Inventory, p 3-44/45.

Growth surrogate for area sources is population. Population growth factor from 1990-1996 is 1.16 (AMS 24-01005-000), 1996 Baseline Projection Inventory, p. 60. Seitz memo “Credit for the 15% ROP Plans for Reductions from the AIM Coating Rule and the Autobody Refinishing Rule,” November 29, 1994.

effectiveness and 100% rule penetration.

1990 area sources = 3.48 tpd = 6,951 ppd

1996 reduction = 0.37 x 6,951 x 1.16 = 2983 ppd = 1.36 mt/d






Bulk Plants MCESD Rule 351- Base year inventory: 1990 Base Year Reduction is from a change in emission limit to 0.8 lb/1000 gal. from and Loading of Organic Inventory, p. 2-21. 0.23 lb/1000 gal. Terminals Liquids Growth surrogate for bulk plants is 1990 inventory is 10052 ppd - 22 ppd (3001) - 102 ppd (1209) - 134 ppd loading ADOT/MAG with a growth factor from

1990-1996 of 1.06, 1996 Baseline Projection Inventory, p. 33 (example source 3324). Revised growth/control factors are from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 3 and table 4 (p. 10).

(1218) - 95 (3301) = 9669 ppd Growth factor is 1.06 Rule effectiveness is 80% Only 77.4% of the emissions from the affected sources come from tank truck loading operations Emission reductions = 9669 ppd x 1.06 [0.774 x 0.8 x (1 - 0.08/0.23)]

= 4139 ppd or 1.88 mt/d

Architectural MCESD Rule 335- Base year inventory: 1990 Base Year 1990 inventory was 27,482 ppd and Architectural coatings Inventory, p. 3-43 and 1996 Baseline Growth factor is 1.16 industrial Projection Inventory, p. 27 (AMS 24-01 Estimated control is 20 percent (1996 Baseline Projection Inventory, p. coatings 001-000).

Growth surrogate for architectural coatings is population with a growth factor from 1990-1996 of 1.16, 1996 Baseline Projection Inventory, p. 60 (AMS 24-01-001-000).

10) Rule effectiveness is 80%

Emission reductions = 27,482 x 1.16 x 0.2 x 0.8 = 5100 ppd or 2.32 mt/d

Highway MCESD Rule 335- Base year inventory: 1996 Baseline Reduction is from a change in emission limit from 3.5 lb/gal to 2.1 lb markings Architectural coatings Projection Inventory, p. 27 (AMS 24-01

008-000). Growth surrogate for vehicle refueling is population with a growth factor from 1990-1996 of 1.16. 1996 Baseline Projection Inventory, p. 60 (AMS 24-01008-000).

gal 1990 inventory is 3,495 ppd Growth factor is 1.16 Rule effectiveness is 80%

Emission reductions = 3,495 x 1.16 x 0.80 x (1-2.1/3.5) = 1,230 ppd or 0.56 mt/d






Stage II Vapor Recovery

A.R.S. 41-2134 Base year inventory: 1990 Base Year Inventory, p. 3-20. Growth surrogate for vehicle refueling is ADOT/MAG with a growth factor from 1990-1996 of 1.06. Revised growth/control factors are from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 2.

No reductions from improved rule effectiveness.

1990 area sources = 25,824 ppd

Controlled emissions from stage II vapor recovery is 1.01 g/gal at 83 percent RE or 1.01 g/gal x 83/77 at 77 percent = 1.09 g/gal Uncontrolled emissions from gasoline refueling are 4.52 g/gal Control effectiveness is 1 - 1.09/4.52 = 0.759

1996 reduction = 25,824 ppd x 1.06 x 0.759 = 20,776 ppd = 9.44 mt/d

Stage I Vapor Recovery

MCESD Rule 353 -Transfer of Gasoline into Stationary Storage Dispensing Tanks

A.R.S. 41-2134

Base year inventory: 1990 Base Year Inventory, p. 3-17. Growth surrogate for tank truck unloading is ADOT/MAG with a growth factor from 1990-1996 of 1.06, 1996 Baseline Projection Inventory, p. 58 (AMS 25-01-060-053). Revised growth/control factors are from Air Quality Bill Based 1996 and 2005 Projection Growth Factors for VOC Emissions, p. 2. Note emission reduction factor for P-V valves is incorrect, the correct factor is 0.475 lb/1000 gal (Meeting the 15-Percent Rate of Progress Requirement Under the Clean Air Act: A Menu of Options, p. 218).

98% of unloading is done through balance fill and 2% by submerged fill Base emissions =10,135 ppd (assumes 90% control effectiveness and a 80% rule effectiveness and an emission factor of 3.28 lb/1000 gal for balance and 7.027 for submerged, composite factor is 0.98x3.28 + 0.02x7.027 = 3.35 lb/1000 gal) Corrected emission factor using P-V value improvement is 3.28 - 0.475x0.8 = 2.90 lb/1000 gal assuming no improvement in rule effectiveness for balance fill 7.027 - 0.475x0.8 = 6.65 lb/1000 gal assuming no improvement in rule effectiveness for submerged fill Composite emission factor is 0.98x2.9 + 0.02x6.65 = 2.975 lb/1000 gal

1996 emission reduction = 10,135 ppd x 1.06 x (1 - 2.975/3.35) = 1,203 ppd or 0.55 mt/d






National National rule proposed Base year inventory: 1990 Base Year See Table 4-4 in Appendix 4 Architectural on June 25, 1996 Inventory, p. 3-43 and 1996 Baseline and (61 FR 32729) Projection Inventory, p. 27 (AMS 24-01 1996 Reduction = 1348 ppd Industrial 001-000). = 0.61 mt/d Maintenance Growth surrogate for architectural Rule coatings is population with a growth

factor from 1990-1996 of 1.16. 1996 Baseline Projection Inventory, p. 60. Control estimates are from Architectural Coatings - Background for Proposed Standards, Emissions Standards Division, OAQPS, U.S. EPA. March 1996.



TABLE 16 SUMMARY OF EMISSION REDUCTIONS FROM POINT AND

AREA SOURCE CONTROLS

RULE YEAR REDUCTION

(MT/D)

Rule 331 - Solvent Cleaning 1996 3.08

Rule 335 - Architectural Coatings 1996 2.32

Traffic marking coatings 1996 0.56

Rule 336 - Surface Coating 1996 0.53

Rule 337 - Graphic Arts 1996 2.30

Rule 342/346 - Wood Coating 1996 0.91

Rule 343 - Bakeries 1996 0.38

Rule 351 - Bulk Loading 1996 1.88

Stage I Vapor Recovery 1996 0.55

Stage II Vapor Recovery 1996 9.44

National Rule - Consumer and Commercial Products

1998 2.5

National Rule - Autobody Refinishing

1998 1.36

National Rule - AIM 1999 0.61

Total 26.42

TABLE 17 TOTAL CONTROLLED EMISSIONS FROM

STATIONARY POINT AND AREA SOURCES (METRIC TONS PER DAY)

CATEGORY 1990 BASE YEAR

1996 CONTROLLED

Point 23.2 18.2

Area 110.8 93.3

Total 134 111.5



2. Non-Road Mobile Sources

Non-road mobile sources include airplanes, trains, and gasoline- and diesel-powered engines used in construction, lawn and garden care, agriculture, and business. There are currently no creditable controls on VOC emissions from airplanes, trains, and diesel-powered engines. For gasoline-powered engines, however, VOC emissions are limited by volatility (RVP) limits on gasoline, reformulated gasoline, and the national non-road engine standards promulgated on July 3, 1995 (60 FR 34582).

Reductions in emissions from gasoline-powered non-road engines result from Arizona’s RVP limit of 7.0 psi which was approved on June 11, 1997 (62 FR 31734) and federal reformulated gasoline program which was approved for the Phoenix area on June 3, 1997 (62 FR 30260). EPA has recently approved Arizona’s Clean Burning Gasoline (CBG) Program (63 FR 6653 (February 10, 1998)) which is will eventually replace the federal RFG program.5 Arizona CBG program is designed to more stringent than the federal RFG program, so there should not be loss of emission reductions as a result of the transition to the State’s RFG program. a. Emission Reductions from RVP Limits

Guidance on calculating the emission reductions from the use of lower-RVP fuel and reformulated gasoline in non-road engines is found in Memorandum, Phillip Lorang, Director, Emission Planning and Strategies Division, Office of Mobile Sources, U.S. EPA, to Regional Air Division Directors, “VOC Emission Benefits for Nonroad Equipment with the Use of Federal Phase 1 Reformulated Gasoline,” August 18, 1993 (“Lorang memo”).

The 1990 base year inventory assumed a 9 pound per square inch (psi) RVP for evaporative (Lorang memo, p. 5) and 12.5 psi RVP for refueling (Lorang memo, p. 7). Emission reductions resulting from reducing RVP from these levels to 7.8 psi, the Federal Phase I limits, are not creditable to the 15 percent plan under CAA section 182(b)(1)(D)(ii). Reductions from 7.8 psi to the approved State limit of 7 psi are fully creditable. RVP limits affect only evaporative and refueling emissions from non-road engines; they have no effect on exhaust emissions. Emission reductions from RVP limits on evaporative and refueling emissions are shown in Tables 18 and 19.

5On September 12, 1997, the Governor of Arizona requested to opt the Phoenix area out of the federal RFG program.



TABLE 18 REDUCTIONS FROM RVP LIMITS

ON EVAPORATIVE EMISSIONS FROM NON-ROAD ENGINES

RVP CHANGE PERCENT REDUCTION CREDITABLE/UNCREDITABLE

9 psi to 7.8 psi 8.9 Uncreditable

7.8 psi to 7.1 psi 3.2 Creditable


Total 3.7 / 8.9 Creditable / uncreditable. Source: Lorang memo, p. 6. The figure for the 7.1 psi to 7.0 psi number extrapolated from other data on the table.

TABLE 19 REDUCTIONS FROM RVP LIMITS

ON REFUELING EMISSIONS FROM NON-ROAD ENGINES

RVP CHANGE PERCENT REDUCTION CREDITABLE/UNCREDITABLE

12.5 psi to 7.8 psi 61.1 Uncreditable



Total 11.4 / 61.1 Creditable / uncreditable. Source: Lorang memo, p. 7. The figure for the 7.1 psi to 7.0 psi number extrapolated from the data on the table.

b. Emission Reductions from Federal Phase I Reformulated Gasoline

VOC benefits from Phase I RFG (7.1 psi RVP) are 3.3 percent from exhaust emissions and 3.5 percent from evaporative emissions in class B areas such as Phoenix. Lorang memo, p. 1. RFG’s evaporative emission benefits come principally from the reduction in RVP and are accounted for in calculating the emission reduction from RVP limits.

For two-stroke gasoline engines, exhaust emissions contribute 96.03 percent of total emissions; evaporative, 1.23 percent; and refueling, 2.74 percent. For four-stroke gasoline engines, exhaust emissions contribute 86.1 percent of total emissions; evaporative, 5.1 percent; and refueling, 8.8 percent. 1993 Ozone Plan, Addendum, Exhibit 3, Measure O and P, Reduced Gasoline Volatility.

Tables 20 through 23 provide the composite emission reduction percentages for RFG and RVP.



TABLE 20 2-STROKE GASOLINE ENGINES - RFG EFFECTS

EMISSION CATEGORY

REDUCTION CONTRIBUTION TO TOTAL GASOLINE VOC EMISSIONS

APPORTIONED REDUCTION

NONCREDITABLE CREDITABLE

Exhaust 3.3% 96.03% - 3.17%

Table 21 2-STROKE GASOLINE ENGINES - RVP EFFECTS

EMISSION CATEGORY

REDUCTION CONTRIBUTION TO TOTAL

GASOLINE VOC EMISSIONS


UNCREDITABLE

CREDITABLE

UNCREDITABLE CREDITABLE

Evaporative 8.9% 3.7% 1.23% 0.11% 0.05%

Refueling 61.1% 11.4% 2.74% 1.67% 0.31%

Total with RFG

1.78% 0.81%

5.76%

TABLE 22 4-STROKE GASOLINE ENGINES - RFG EFFECTS

EMISSION CATEGORY




NONCREDITABLE CREDITABLE

Exhaust 3.3% 86.1% - 2.84%



Table 23 4-STROKE GASOLINE ENGINES - RVP EFFECTS

EMISSION CATEGORY




UNCREDITABLE

CREDITABLE

UNCREDITABLE CREDITABLE

Evaporative 8.9% 3.7% 5.1% 0.45% 0.19%

Refueling 61.1% 11.4% 8.8% 5.38% 1.00%

Total with RFG

5.88% 1.19%

9.91%

Emission reductions from each category of non-road engines are given in Tables 5-1 (RVP) and 5-2 (RFG) in Appendix 5 and are summarized in Table 24. Base year inventories and growth factors are taken from “1996 Baseline Projection Inventory for Volatile Organic Compounds (VOC) Emissions, Final Submittal,” January 1994, Maricopa County Environmental Management and Transportation Agency found in Exhibit 4 to the 1993 Ozone Plan Addendum.

TABLE 24 SUMMARY OF REDUCTIONS FROM 7.0 PSI RVP LIMITS AND FEDERAL PHASE I

REFORMULATED GASOLINE IN NON-ROAD ENGINES (POUNDS PER DAY)

CATEGORY 1990

BASE YEAR

1996 ADJUSTED

INVENTORY 1

1996 WITH UNCREDIT.

RVP REDUCTION

1996 WITH CREDITABLE

RVP REDUCTION

1996 WITH RFG

REDUCTION

2-stroke engines 43,300 42,529 40,924 40,586 39,300

4-stroke engines 61,220 57,620 56,320 55,608 54,029

Totals (ppd) 106,510 102,145 99,240 98,190 95,325

Totals (mt/d) 48.4 46.4 45.1 44.6 43.3

Reductions (mt/d)

- 2.0 1.3 0.5 1.3

1 To determine the 1996 adjusted inventory for the 15 percent calculation, the same basic principle is applied to the non-road engines as was applied to on-road, that is the inventory is the 1996 projected levels of control at 7.8 psi is applied to the 1990 level of activity.



c. Emission Reductions from Federal Non-Road Engine Standards

On July 3, 1995, EPA promulgated Phase I emission standards for new spark-ignition (gasoline) engines of 25 horsepower or less. These engines include those typically used in lawnmowers and other residential gardening equipment, commercial lawn and garden equipment, and small pumps and compressors, and some other industrial/construction equipment. The Phase I standards were effective with model year 1997 engines and are expected to reduce emissions from the impacted equipment types by 4.5 percent in 1996, 12.8 percent in 1997, 19.0 percent in 1998, and 22.9 percent in 1999. See Memorandum, Philip A. Lorang, Director, Emission Planning and Strategies Division, OMS to Regional Air Division Directors; “Future Nonroad Emission Reduction Credits for Court-Ordered Nonroad Standards;” November 29, 1994 (Lorang memo II).

Emission reductions from each category of non-road engines are given in Tables 5-3 (1996), (5-4) 1997, 5-5 (1998) and 5-6 (1999) in Appendix 5 and are summarized in Table 25. Note that emission reductions are calculated from a base that assumes the implementation of RFG and RVP per Lorang memo II, p. 11.

TABLE 25 SUMMARY OF REDUCTIONS FROM

THE FEDERAL NONROAD ENGINE STANDARDS (POUNDS PER DAY)

CATEGORY 1996

CONTROLS (NO RFG)

1997 CONTROLS

1998 CONTROLS

1999 CONTROLS

2-stroke engines

38,817 34,395 32,036 30,552

4-stroke engines

53,335 47,641 44,605 42,695

Totals (ppd) 92,152 82,036 76,641 73,247

Totals (mt/d) 41.9 37.3 34.8 33.3

Base 96,194 93,328 93,328 93,328

Reduction (ppd)

4,042 11,292 16,687 20,081

Reductions (mt/d)

1.8 5.1 7.6 9.1



d. Summary of Non-Road Emissions Inventory

The controlled emissions from gasoline-powered nonroad equipment must be summed with the emissions from planes, trains, and diesel-powered equipment to determine the total emission inventory in the non-road category. Table 26 provides a summary of emissions from all nonroad categories. Inventories for planes, trains, and diesel-powered nonroad equipment are taken from 1996 Baseline Projection Inventory and are summarized in Tables 5-7 (diesel engines) and 5-8 (airplanes and trains) in Appendix 5.

TABLE 26 SUMMARY OF NONROAD EMISSIONS

(POUNDS PER DAY)

CATEGORY 1996

CONTROLS 1997

CONTROLS 1998

CONTROLS 1999

CONTROLS

2-stroke engines 38,817 34,395 32,036 30,552

4-stroke engines 53,335 47,641 44,605 42,695

Diesel engines 15,628 15,628 15,628 15,628

Airplanes 3,068 3,068 3,068 3,068

Locomotives 1,726 1,72

Documents

Phoenix Area Ozone Actions · percent plan for the Phoenix area which is contained in the MAG 1993 Ozone Plan for the Maricopa County Area (November 1993) (MAG 1993 Plan) and its